Privacy Policy & Initial California Privacy Notice

Updated: 9/15/2021

Overview

RF Renovo Management Company, LLC along with and on behalf of its subsidiary and affiliated companies (collectively “Renovo”) operates this website and maintains this Privacy Policy presented below (this “Privacy Policy”). This Privacy Policy applies to visitors to this website, visitors to Renovo’s offices, individuals who speak with Renovo personnel via telephone, third-party service providers, vendors and suppliers, business contacts, prospective clients, current clients, investors, employees and other Renovo personnel, and any user of Renovo’s website or services more broadly (the “End Users”). This Privacy Policy specifies how Renovo processes information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific individual (the “Personal Information”).

The Initial California Privacy Notice required under the California Consumer Privacy Act of 2018 (“CCPA”) is integrated into this Privacy Policy. Renovo is providing the information in this Privacy Policy to comply with the CCPA and other applicable laws.

Information We Collect

Renovo may collect, and has collected in the preceding 12 months, Personal Information through its website or via submission of information to its employees via hard copy, email, telephone or by other electronic means. Such Personal Information falls in the following categories:

Category

Examples (Not all will be collected)

Identifier

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol Address, email address, account name, account password, Social Security number, driver’s license number, passport number, or other similar identifiers.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80 (e))

A name, signature, Social Security number, physical characteristics or descriptions, address, telephone number, passport number, driver’s licenses or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or any other financial information, medical information or health insurance information. Some personal information included in this category may overlap with other categories.

Protected classifications characteristics under California or Federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical conditions, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Commercial or financial information

Financial records and historical financial information, investment and insurance records, or records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Legal and criminal records

Information and records related to any and all prior judgments, bankruptcies, foreclosures, legal matters, alimony, child support, separate maintenance, liens filed against you or your business or other similar information.

Internet or other similar network activity

Browsing history, search history, information about a consumer’s interaction with a website, application or advertisement.

Geolocation data

Physical location or movements.

Professional, residency, or employment related information

Current or past job history, performance evaluations, current and former state or national residency status, and real estate investment history and records.

Education information

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grade, transcripts, class lists, student schedules, student identification codes, and student financial information or student disciplinary records.

Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior attitudes, intelligence, abilities and aptitudes.

Sources From Which We Collect Personal Information

In most cases, Renovo collects Personal Information directly from End Users. End Users will usually know when Renovo collects Personal Information because End Users will actively provide it to Renovo for a stated purpose. Renovo may also collect Personal Information from the following additional categories of sources:
• Service providers.
• Government entities.
• Consumer data resellers.
• Data analytics providers.
By its nature, Renovo’s website may also automatically collect some Personal Information. For an End User to view or interact with Renovo’s website, individual identifiers like IP address and some network information like date and time of pages visited is collected. Renovo may collect some Personal Information automatically using cookies or other tracking technologies, described in more detail in the cookies section below. Personal Information may be automatically collected by or on behalf of third parties who provide Renovo inferences or reporting based on analysis of such Personal Information.

Use of Personal Information

Renovo may use Personal Information to perform services, including maintaining or servicing accounts, providing customer service, processing or fulfilling deals or transactions, verifying customer information, processing payments, providing financing, or tracking the usage of its website. Even if Renovo does not retain information, it still will be transmitted to servers initially and stored long enough to process.
Renovo may also use Personal Information for the following business or commercial purposes:
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• To give End Users information on our products and services.
• To provide End Users with requested information regarding Renovo’s products and services.
• To fulfill any other purpose for which an End User provided it.
• To provide End Users notices about their account.
• To carry out Renovo’s obligations and enforce Renovo’s rights arising from any contracts entered into between End Users and Renovo, including billing and collection.
• To process a request for a loan.
• To create, maintain, and secure an End User account.
• To provide support to End User inquiries by validating requestor personal information.
• To respond to law enforcement requests as required by applicable law, court order or governmental regulations.
• For research and analysis to improve Renovo’s website and or any mobile application, if applicable.
• To evaluate and analyze the sale or transfer of Renovo assets, including but not limited to Renovo’s servicing portfolio.
• For any purpose with the applicable End User’s consent.

Cookies

Through the use of cookies and similar technologies, Renovo may collect your device IP address, unique device ID, hardware and software type, Internet service provider, serving domain, geographical area, location data, browser type and settings data (such as language, screen resolution, color depth, time zone settings, browser extension and plugins) operating system, referring URLs, search history, information on actions taken or interaction with our digital assets (e.g., page views, x/y coordinates of mouse events) and dates and times of actions.

The types of cookies Renovo may use include Google Analytics to collect information about how End Users use Renovo’s website. Renovo may use this information to create reports and improve its website. The cookies help Renovo understand the number of visitors to its website and where visitors come from. To opt-out from these cookies across all websites, visit http://tools.google.com/dlpage/gaoptout.

Many web browsers allow individuals to manage cookies through their browser settings. Be aware that, opting-out from and not agreeing to certain cookies may diminish an End User’s experience on Renovo’s website and some features may not work as intended depending on the cookie. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org. Please note that opting-out of cookies, tags, and pixels only pertains to the device and the browser that you are using when you opt-out.

Important Rights Regarding Personal Information

Where applicable, End Users who are California residents have the following rights under the CCPA in relation to Personal Information collected as defined in the CCPA; these rights are granted to the extent required by the CCPA and are subject to verification and any applicable exceptions:
• Eligible End Users have a right to know about Personal Information collected, used, disclosed, or sold by Renovo.
• Eligible End Users have a right to know about Renovo’s practices regarding the disclosure or sale of Personal Information. Please note that Renovo does not sell Personal Information.
• Eligible End Users have a right to request deletion of Personal Information.
• Eligible End Users have a right to opt-out of the sale of Personal Information. However, as noted, Renovo does not engage in the sale of Personal Information.
• Eligible End Users have a right not to receive discriminatory treatment by Renovo for the exercise of the privacy rights conferred by the CCPA.
To exercise or inquire about any of the rights described above, or to submit any inquiries or express any concerns about Renovo’s privacy policies and practices, please contact Renovo using one or both of the above below:
• Calling us toll-free at +1 (888) 568-8894
• Emailing us at inquiries@renovofinancial.com
Renovo will need to verify the identity of any person making such a request or exercising the rights described above. The End User submitting a request or exercising one of the rights above must provide enough information to verify their identity and address, and a description of what right they wish to exercise along with any information to which their request relates. Only the End User, or someone legally authorized to act on the End User’s behalf, may make a verifiable request related to Personal Information collected about a specific End User. To designate an authorized agent, the authorized agent must provide sufficient information that allows Renovo to reasonably verify that they have been authorized by the relevant End User to act on their behalf. For requests which could lead to the potential disclosure or deletion of sensitive information about an End User, for instance a social security number, Renovo may require a heightened level of verification.

Links to Third-Party Websites

Renovo’s website may contain links to third party websites which, in some cases, may be integrated into, and appear to be part of, the Renovo’s website. Renovo encourages all End Users to read the privacy policies of other websites and disclaims any responsibility for the privacy policies and procedures of any third-party websites that End Users reach via a hyperlink contained on Renovo’s website. Such hyperlinks are provided for your convenience only, and you access them at your own risk.

Children's Personal Information

Renovo’s website is not intended for or targeted towards, and Renovo does not knowingly collect Personal Information via this website from, children under 18 years of age.

Updates to the Privacy Policy

Renovo reserves the right in its sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting and we will indicate in the Privacy Policy when it was most recently updated. Users of Renovo’s website should review this Privacy Policy periodically for any applicable changes. Additionally, note that by accessing Renovo’s website subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended.